Correction, July 27, 2026. The version of this article published on June 15, 2026 stated that CMS had finalized a rule expanding the qualifying life events that trigger an ACA Special Enrollment Period, and went on to describe several specific new triggers. That was incorrect. No 2026 rule expanded Special Enrollment Period eligibility. Federal action over this period moved in the opposite direction. The article below has been rewritten in full and re-sourced to CMS final rule documents. We have left this notice in place rather than quietly removing the record of the error.
Special Enrollment Periods are the mechanism that lets people buy ACA Marketplace coverage outside the annual Open Enrollment window. They have been the subject of active federal rulemaking and live litigation since 2025, and the direction of travel has been toward tighter eligibility and more documentation, not looser.
What a Special Enrollment Period Is
Open Enrollment is the primary window for selecting or changing a Marketplace health plan. Outside that window, enrollment is generally limited to people who experience a qualifying life event, which opens a Special Enrollment Period (SEP). Longstanding triggers include losing job-based health coverage, getting married, having or adopting a child, permanently moving to a new coverage area, losing Medicaid or CHIP eligibility, and aging off a parent's plan at 26.
A SEP generally gives you 60 days from the date of the qualifying event to enroll in a new plan. That window is firm. Missing it usually means waiting until the next Open Enrollment Period, which is how coverage gaps of several months happen.
What the 2025 Marketplace Integrity Rule Changed
On June 20, 2025, CMS issued the Marketplace Integrity and Affordability Final Rule, published in the Federal Register at 90 FR 27074. CMS framed the rule as a response to improper and unauthorized enrollments. Two of its provisions bear directly on special enrollment.
- The 150 percent FPL special enrollment period was eliminated. This was a monthly enrollment opportunity available to people with household incomes below 150 percent of the federal poverty level. CMS identified it as a significant driver of unauthorized enrollments. Its removal is the change that matters most for lower-income households: low income by itself no longer opens an enrollment window.
- Pre-enrollment verification was extended. The federal Marketplace had generally asked for proof of SEP eligibility only when the qualifying event was loss of other coverage. The rule removed that limitation, opening the door to verification across other SEP categories.
The Court Stay
Several of the rule's provisions did not take effect on schedule. In City of Columbus v. Kennedy, No. 25-cv-2114-BAH in the U.S. District Court for the District of Maryland, a federal judge stayed a number of them on a nationwide basis, and the Fourth Circuit declined to grant the government emergency relief from that decision. The SEP pre-enrollment verification requirement was among the provisions placed on hold while the case proceeded.
This is why coverage of ACA enrollment rules during this period is genuinely confusing to read. A provision can be finalized, reported as finalized, and still not be in force.
How the 2027 Payment Notice Restored the Verification Requirement
CMS returned to the question in the HHS Notice of Benefit and Payment Parameters for 2027 Final Rule. According to the CMS fact sheet for that rule, CMS re-finalized the pre-enrollment SEP verification requirement for Exchanges on the federal platform. The refinalized policy allows those Exchanges to conduct verification for SEP categories beyond loss of minimum essential coverage, and requires them to verify eligibility for at least 75 percent of new enrollments made through a Special Enrollment Period.
The language in the CMS materials is worth reading carefully, because it is the source of a common misreading. CMS describes verification for additional SEPs. That means additional categories of special enrollment become subject to proof. It does not mean additional categories of special enrollment now exist. The earlier version of this article inverted exactly that distinction.
For broader coverage of the same rule, see our report on the 2027 ACA Payment Notice.
What This Means in Practice
If you are enrolling through a SEP on the federal platform, assume you will be asked to prove your qualifying event, and assemble the documentation before you start the application rather than after. Typical proof includes:
- Loss of job-based coverage: a letter from the employer or the plan stating the date coverage ended
- Marriage: a marriage certificate
- Birth or adoption: a birth certificate, adoption record, or placement order
- Permanent move: documents showing the previous address, the new address, and the date of the move
- Loss of Medicaid or CHIP: the termination notice issued by your state agency
State-based Marketplaces are not all governed by the federal platform rules and retain flexibility over their own verification requirements. If your state runs its own exchange, check that exchange rather than assuming the federal position applies to you.
Two practical points follow from the 60-day clock. Count forward from the date of the event, not from the date you noticed it. And start the application while you are still gathering paperwork, because the deadline applies to the application, not to the document upload.
If You Do Not Have a Qualifying Event
Options are narrower than they were, but they are not zero.
- Medicaid and CHIP have no enrollment deadline. If your income has fallen, eligibility is worth checking at any point in the year.
- If you are under 26, you may be able to join or rejoin a parent's plan, subject to that plan's own rules.
- Short-term limited-duration plans exist as a bridge, but understand what you are buying. They are not minimum essential coverage, they are generally free to exclude pre-existing conditions, and losing one does not itself open a Special Enrollment Period.
- COBRA may be available if you left a job with employer coverage. See our guide to how COBRA works for the deadlines and cost structure.
Verify Before You Rely on Any of This
This area has changed more than once in two years, parts of it have been litigated, and at least one provision has been finalized, stayed, and finalized again. Before you act, confirm the current position on HealthCare.gov or with your state Marketplace, both of which reflect the rules actually in force rather than the rules as most recently announced.
To estimate what a Marketplace plan would cost you, use our Health Insurance Calculator. For how premium tax credits are calculated and who qualifies, see our guide to ACA subsidies and premium tax credits.